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TPDES General Permits
CWI Workshop TPDES MSGP
5/17/2012 Page 2
TPDES Permit Expiration
Date
Status No. of
Authorizations
TXR050000
MSGP
Aug 14, 2016 Renewed in
2011
8,000
TXR040000
Phase II MS4s
Aug 13, 2012 Renewal Begun
in 2011
403
TXR150000
Storm Water
Construction
Mar 5, 2013
Processing
NOIs
11,419
Applicability
Industrial activities are grouped into 30 sectors of similar
activities based on either Standard Industrial Classification
(SIC) codes or Industrial Activity Codes.
CWI Workshop TPDES MSGP
5/17/2012 Page 3
Industry Sectors
CWI Workshop TPDES MSGP
5/17/2012 Page 4
A. Timber Products
B. Paper and Allied Products
C. Chemical and Allied Products
D. Asphalt Paving and Roofing
Materials and Lubricants
E. Glass, Clay, Cement, Concrete,
and Gypsum Products
F. Primary Metals
G. Metal Mining (Ore Mining and
Dressing)
H. Coal Mines and Coal Mining
Related Facilities
I. Oil and Gas Extraction
J. Mineral Mining and Dressing
K. Hazardous Waste Storage
Facilities
L. Landfills and Land Application
Sites
M. Automobile Salvage Yards
N. Scrap Recycling Facilities
O. Steam Electric Generating
Facilities
P. Land Transportation and
Warehousing
Q. Water Transportation
R. Ship and Boat Building or
Repairing Yards
S. Air Transportation
T. Treatment Works
Industry Sectors, cont.
CWI Workshop TPDES MSGP
5/17/2012 Page 5
U. Food and Kindred Products
V. Textile Mills, Apparel, and Other
Fabric Product Manufacturing,
Leather and Leather Products
W. Furniture and Fixtures
X. Printing and Publishing
Y. Rubber, Miscellaneous Plastic
Products, and Miscellaneous
Manufacturing Industries
Z. Leather Tanning and Finishing
AA. Fabricated Metal Products
AB. Transportation Equipment,
Industrial or Commercial
Machinery
AC. Electronic, Electrical,
Photographic, and Optical
Goods
AD. Miscellaneous Industrial
Activities
Highlights of Changes in Renewed MSGP
CWI Workshop TPDES MSGP
5/17/2012 Page 6
http://www.tceq.texas.gov/assets/public/
permitting/stormwater/txr050000.pdf
Automatic Authorization Option
CWI Workshop TPDES MSGP
5/17/2012 Page 7
Automatic authorization option for additional industrial facility operators. Requires a condition of no exposure, and does not require operator to submit any forms to TCEQ. This option added for the following facilities: • Operators of regulated facilities that occur within a residential home,
shopping mall, or office building, and that have no exposure of any regulated activity to storm water.
• Operators of publishing and designing companies that do not perform
printing activities and that do not have exposure of any regulated activity to storm water.
Paper Application Changes
CWI Workshop TPDES MSGP
5/17/2012 Page 8
Changes to requirements for paper application forms: • Extend time required to await provisional coverage after submitting a
paper NOI from two (2) to seven (7) days, • Increase for paper application fee by $100 for operators submitting a
paper NOI or NEC form. The new fee for paper NOIs and NECs is $200. The electronic application fee remains the same at $100.
• Removal of the option for facilities utilizing electronic filing to have an
extra 30 days to renew coverage, as other incentives are being proposed (i.e., application fee incentive and difference in the date that authorization begins).
New WQ Monitoring Requirements for Discharges to
Impaired Water Bodies
CWI Workshop TPDES MSGP
5/17/2012 Page 9
• Must determine if any discharges are to impaired water body with an approved TMDL.
• Must comply with TMDL requirements and incorporate any TCEQ
conditions into SWP3, including monitoring frequency and reporting. • Existing dischargers must comply with TMDL and I-Plan. If TMDL or I-
Plan do not identify additional monitoring, then not required. • New dischargers must sample for pollutant of concern in TMDL and I-
Plan. If first year sampling shows pollutant is below level of concern or not present, no additional sampling required.
Changes to Benchmark Sampling
CWI Workshop TPDES MSGP
5/17/2012 Page 10
• Revision of benchmark levels based on data that were submitted during calendar years 2007 and 2008. Some were increased, others were decreased; and these changes were done on a pollutant-by-pollutant basis.
• New benchmark sampling requirements in Sector AD (Miscellaneous
Industrial Activities) for pollutants commonly regulated in individual storm water permits: pH, COD, TSS, and oil and grease.
• New waiver option for benchmark sampling during Years 3 and 4, if
sampling during Years 1 and 2 demonstrates that the annual average result for all benchmark parameters is below the benchmark level for the regulated sector. (Waiver is NOT applicable to hazardous metals.)
Qualifying Event
CWI Workshop TPDES MSGP
5/17/2012 Page 11
Revisions to clarify that a precipitation event is considered representative, or “qualifying,” based on the fact that it produces a discharge, rather than based on the measured amount of precipitation (i.e., previously a representative storm event would include at least 0.1 inch of measured precipitation). This change is consistent with the EPA’s MSGP.
No Exposure Clarification
CWI Workshop TPDES MSGP
5/17/2012 Page 12
Added language from TCEQ’s No Exposure Guidance Document (RG-467) clarifying the meaning of “no exposure” of industrial activity.
What is “No Exposure”?
No exposure means that all industrial activities
are conducted indoors or protected by a storm-
resistant shelter to prevent exposure of those
activities to rain, snow, snowmelt, or runoff.
Clarifications for Individual Sectors
CWI Workshop TPDES MSGP
5/17/2012 Page 13
Several clarifications to individual industrial sectors, including clarification on allowable non-storm water discharges, prohibited discharges, additional SWP3 requirements, effluent limitations applicability, and benchmark sampling.
Continued Requirements
CWI Workshop TPDES MSGP
5/17/2012 Page 14
• Develop or Revise SWP3 and Submit NOI and Fee to TCEQ
• Also need to send NOI to MS4 Operator
Continued Requirements
CWI Workshop TPDES MSGP
5/17/2012 Page 15
• Site Drainage and Potential Pollutant Sources • Storm Water Pollution Prevention Team • Site Location Map and Site Plan • Routine Facility Inspections (at least Quarterly) • Annual Comprehensive Site Compliance Inspection • Quarterly Visual Monitoring • Hazardous Metals Monitoring (Numeric Limitations) • Benchmark Monitoring • Sector-Specific Requirements (More Specific) • Record Retention • Reporting
Additional Local Requirements
CWI Workshop TPDES MSGP
5/17/2012 Page 17
• City of Houston and Harris County
• Phase II MS4 Operators
• Tenant Requirements
Effective Measures
CWI Workshop TPDES MSGP
5/17/2012 Page 19
• Eliminate Sources
• Cover Material Storage Areas
• Use Appropriate Best Management Practices
• Inspections
• Training
• Good Housekeeping – Create Culture of Pollution Prevention
• Addition to Onsite Treatment Train
Training Criteria
CWI Workshop TPDES MSGP
5/17/2012 Page 23
Education will be provided to those employees at the facility who are
not directly responsible for implementing or maintaining activities in
the SWPPP and who do not participate in the employee training
program. At a minimum, these employees must be informed of the
basic functions of the SWPPP and how to contact the facility’s storm
water PPT regarding storm water issues.
All field employees and supervisors who are responsible for
implementing aspects of the SWPPP will be provided annual training
in the following areas:
1. Goals and Functions of the SWPPP
• Minimize the contamination of onsite storm water prior to
discharge into the receiving stream.
• Provide a framework of best management practices (BMPs) to
achieve minimization.
• Set up process for annual review of the effectiveness of the
SWPPP.
Training Criteria, cont.
CWI Workshop TPDES MSGP
5/17/2012 Page 24
2. Spill Prevention and Control
• Spill prevention methods
• Location of spill and response equipment
• Use of sorbents and other spill control/cleanup materials
• Spill reporting procedures
3. Proper Waste Handling Procedures
• Materials used for spill cleanup
• Sludge transfer
• Grit/Screenings disposal
Basic Spill Response Procedure SPILL
DISCOVEREDNOTIFY SUPERVISOR
ACTIVATE
RESPONDERS
BOOM SPILL
AND/OR
PLACE SORBENT
REQUEST SEVERN TRENT
SERVICES SPILL RESPONSE
UNIT
AND/OR
OUTSIDE RESPONSE
CONTRACTOR
IS RESPONSE
WITHIN THE CAPABILITIES
OF
THE SITE?
CONDUCT
CLEANUP
PROPERLY DISPOSE OF
ALL WASTES
SUBMIT REPORTS,
IF NEEDED;
INCIDENT CLOSED
MONITOR CLEANUP
ACTIVITIES
Yes
No
EVALUATE CORRECTIVE
ACTIONS NEEDED TO
PREVENT RECURRENCE
IMMEDIATELY MAKE
AGENCY REPORTS
IF REQUIRED
BASIC SPILL RESPONSE
PROCEDURE
Page 25 CWI Workshop TPDES MSGP 5/17/2012
Training Criteria, cont.
CWI Workshop TPDES MSGP
5/17/2012 Page 26
4. Good Housekeeping and Material Management Practices
• Proper liquids transfer procedures
• Proper sludge handling and transfer procedures
• Proper treatment unit and equipment cleaning
• Proper fueling procedures
• Proper onsite waste management
• Proper petroleum product and chemical management
• Proper procedures for using fertilizers, herbicides, and
pesticides (as applicable)
5. Inspection
• Grit and screenings area
• Treatment units
• Structural controls
• Tanks, pumps, piping, and ancillary equipment
• Daily inspection of liquids and chemical storage areas
6. Storm Water Sampling Techniques
Operational Plans
CWI Workshop TPDES MSGP
5/17/2012 Page 27
• Forms that work
• If using template, customize it to eliminate unnecessary material
• Pre-prepare inspection and spill response reporting forms
Frequently Encountered Issues
CWI Workshop TPDES MSGP
5/17/2012 Page 30
• Blank Forms
• Unsigned Plans
• Certification Language Missing from Inspection Forms
• Personnel Changes Not Updated in Plans
• Open Valves on Containment Drainage Structures
For More Information
CWI Workshop TPDES MSGP
5/17/2012 Page 31
http://www.tceq.texas.gov/permitting/water_quality/
stormwater/TXR05_steps.html
http://cfpub.epa.gov/npdes/stormwater/msgp.cfm
http://cfpub.epa.gov/npdes/stormwater/indust.cfm
Thank You Mary L. Purzer, PE
713.267.3147
Page 32 CWI Workshop TPDES MSGP 5/17/2012